In two previous articles, Shawna Cox brought the matter of Jurisdiction to the Court. The first, explained in "Public Lands - Part 1 - It's a Matter of Jurisdiction", was filed in response to the government's "Motion for Judicial Notice" (1229), providing proof of ownership of the land upon which the MNWR headquarters sit. In that Motion, filed September 9, 2016, they cited no previous motion to which they were responding.
Shawna, based upon a chain of title that she had received, had no dispute with the ownership. However, neither the government's request for judicial notice and attached documentation nor the chain of title provided any indication that the land, which both parties agreed, had been in private hands before the government reacquired it, had been ceded back to them by Oregon.